Summary

This OM provides guidance for inspectors in FOD (for Construction Division see SIM 02/2008/02) on assessing selected topics and recording compliance with them using the revised IRF Other (IRF O) on COIN.  It should be read in conjunction with OM 2008/05 'COIN work recording'.  For guidance on how to complete on COIN an IRF O see "COIN Guidance - Inspection".  As before, the IRF O should be used to record inspections wherever possible: it is expected that this will be following most inspections.

Background

1  The information gathered during proactive work is vital to our ability to assess standards, evaluate the effectiveness of our intervention strategy and target our work.  Following extensive consultation and successful pilots, FOD have agreed with COSAS changes to the way in which we record this information, by:

• moving to a six point scale to improve the sensitivity of the scoring system and enhance its ability to measure change;
• using a single, more detailed descriptor for each topic to better define the standards corresponding to each score and support greater consistency between inspectors.

2  FOD have taken this opportunity to make some further changes to the IRF O.

3  More extensive changes are being made to the IRF C used in Construction Division to reflect the workstreams from their Business Group Delivery Plan.  CD will also move to a six point scoring scale. 

Timing

4  All the changes described in this OM take effect from 31 March 2008.

Changes to the IRF O (see appendices 1 and 2)

5  The following changes have been made:

• adopting a single risk control indicator per topic;
• adopting a six point assessment scale per topic, with revised descriptors;
• introducing new topics for:
  • asbestos management
  • COSHH including health surveillance
• replacing the 'asthmagens' box with a tick list for the topics below, to allow the Disease Reduction Programme to identify the records of visits relevant to projects within the programme:
  • occupational asthma
  • other respiratory disease
  • carcinogens
  • work-related contact dermatitis
• adding two further boxes for completion when these issues are discussed:
  • matters of concern (both evident concern and potential major concern) see also OC18/12
  • REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals Regulations).

The assessment process

6  Whenever one of the topics in appendix 1 has been discussed, consider which element of the assessment scale in appendix 2 best describes the standards found.  Appendix 1 contains a risk control indicator for each topic, to provide a summary of the key issues relevant to each hazard (in the same way that the three indicators in the earlier IRF O did).  Further advice on key issues for most of the topics is in the topic packs.  It is important to use the complete range of scores within the assessment scale, where appropriate, to allow proper differentiation between dutyholders.

7  For each topic, the time spent discussing the issue must also be recorded, using hours and minutes, and the ‘number of notices' box completed.  The function and use of this box has not changed: whenever a notice or notices have been issued, the box should be completed with the number of notices actually issued, not the number that may have been intended to be issued.

8  Where you record a score of 5 or 6 on the IRF O you must record the action taken, and the reason for taking that action, on the inspection SO. Later, you must record the outcome on a new service order (SO), created for the revisit or against the case where formal enforcement action has been taken. You will only need to leave the initiating SO open to record the outcome where you are checking progress by letter or telephone.

9  The IRF O also requires information to be entered against six other issues: occupational asthma, other respiratory disease, carcinogens, work-related contact dermatitis, matters of concern and REACH.  Do not assess these issues against the assessment scale overleaf, but,

• complete the time and 'number of notices' boxes whenever a matter of evident concern or a matter of potential major concern) is discussed;
• complete the time and 'number of notices' boxes whenever REACH is discussed;
• for the remaining issues, simply check the box on the screen for each issue discussed.  There is no requirement to record any time against these issues.

10  The standards that you find on these six issues will feed into the overall safety or health performance ratings.

11  The new risk control indicators and assessment scale are in appendices 1 and 2.  For day-to-day use, a laminated sheet containing the new indicators and scale, as well as the IRS descriptors, will be distributed to staff.

Changes to the Inspection Rating System (IRS) – (see appendix 3)

12  The following changes have been made:

• new descriptors for the 1 to 6 scoring scale for ‘Competence and attitude of management’;
• when rating overall safety or health performance the RCI assessment scale is to be used.

13  For guidance on rating see Report, record and follow up – Additional guidance

Appendix 1

Falls from height: is the dutyholder identifying activities and precautions involving falls from height (bearing in mind the hierarchy of control measures), selecting, using and maintaining equipment appropriately and implementing systems for the procurement and control of contractors?

Slips and trips: are work activities controlled and machinery and buildings maintained sufficiently to minimise floor contamination; is floor drainage adequate; are contamination control measures eg lids, trays, mats etc, being utilised; are spillages quickly removed, is floor cleaning suitable; are floors/footwear adequately slip-resistant and are walkways kept clear and in good condition? 

Workplace transport: are the risks from workplace transport, including visiting vehicles, well controlled?  Are appropriate precautions taken, e.g. for safe site (pedestrians separated from vehicles, traffic routes well set out); safe vehicle (suitable and well maintained); safe driver (all well trained, competent and supervised)?

Musculoskeletal disorders: are managers and workers working together to identify MSD hazards, assess risks and implement necessary control measures; are significant MSD risks well controlled, minimising heavy lifting and repetitive tasks; are mechanical aids used where necessary; are employees provided with suitable instruction and training on risk factors and control measures and do they understand the importance of early symptom reporting?

HAV: has exposure to vibration been reduced to ALARP by adopting alternative working methods (or is a viable plan in place to achieve this); is any continuing and residual risk managed, eg by equipment selection and maintenance, operator training, management of exposure duration; is exposure below the legal limit (where reasonably practicable); and is a suitable health surveillance programme in place?

NOISE: has exposure to noise been reduced to ALARP by organisational and technical means (or is a viable plan in place to achieve this); is any continuing and residual risk managed through providing suitable personal hearing protection, with systems to ensure full and proper use; are management arrangements in place including a positive purchasing policy for quiet equipment; is a suitable health surveillance programme in place?

COSHH including health surveillance: is there effective organisation and arrangements, including adequate assessment, information, instruction and supervision, with evidence of management commitment; are controls adequate, including substitution, engineering controls or PPE; is there suitable health surveillance with records and appropriate reporting and are cases of ill health reported under RIDDOR, where required?

Asbestos management: is a responsible person appointed; is there an asbestos register/building plan for all buildings; is there a written management plan; have workers been trained; do workers know what action to take if ACMs are discovered or disturbed; are there emergency procedures; is there a system to regulate all maintenance/installation work; are there arrangements to review the management plan?

Appendix 2

Risk Control Indicators (RCI) – Assessment Scale Each risk control indicator should be assessed against the following 1-6 scale. NB use this scale when rating the overall safety or health performance - see overleaf.
1	High standards. Some aspects meet best practice.
2	Good standards. Minimum legal requirements have been met.
3	One or more minor short- comings. As these shortcomings are not serious, they can be dealt with informally with oral advice.
4	Standards are patchy. It is necessary to address one or more shortcomings by giving formal instructions for remedial action to be taken. Formal instructions may be implemented by, e.g., obtaining a verbal undertaking from the company to take specific action, sending a letter, or physical removal / disposal of items..
5	Standards generally un-satisfactory. Typically, there is at least one contravention that gives rise to a discernible risk gap.
6	Standards un-acceptable. Unless applying the EMM identifies duty holder factors that provide strong mitigation, issuing a notice and / or prosecution is likely to be appropriate.

Appendix 3

Competence and attitude of management
Rating	Descriptor
1	Management know the relevant health and safety standards have put them into effect and check they are applied correctly. There is clear evidence of effective self-regulation with standards being monitored and refined. Full compliance with the approach in HS(G)65.
2	Management generally enthusiastic and competent with either (i) effective systems in place for other business processes (e.g. quality assurance), but have incomplete knowledge of health and safety requirements, or (ii) good health and safety knowledge with systems requiring improvement. There is potential for good performance and reasonable compliance with the HS(G)65 approach.
3	Management are knowledgeable about relevant health and safety standards but there has been little effort to adopt a proactive approach to health and safety management. However, senior managers volunteer their thoughts as the inspection progresses and appear to be committed to adopting a more proactive approach. There is general confidence that the recommendations resulting from the inspection will be put into place.
4	Management have only a patchy knowledge of relevant standards and there is little or no evidence that a proactive approach to health and safety management has been adopted. However, senior managers recognise the need to satisfy explicit statutory requirements and there is some prospect that a more proactive approach may be adopted.
5	Management show significant shortcomings in their knowledge of relevant standards; they do not appear to be willing to instigate a proactive approach and have not recognised that health and safety is an issue where they need to be personally involved. There is uncertainty as to how they will respond to the findings from the inspection.
6	There is a negative approach to accepting legal duties and management dispute the relevance or validity of recognised benchmark standards. Totally ineffective in the management of health and safety.  The findings from the inspection are likely to be ignored.